Singh v. State

Summary

The Supreme Court of Maryland held that placing Singh in the back of a patrol car did not automatically convert his lawful investigatory detention into a de facto arrest. Considering the totality of the circumstances, the detention was reasonable because officers were investigating a fatal collision, acted without forceful arrest-like tactics, and diligently obtained assistance from specialized officers. The Court also held that Singh was not apprehended for purposes of the statutory two-hour breath-test period until 8:51 a.m., when an officer detected an odor of alcohol and initiated field sobriety testing, making the 10:15 a.m. test timely. The judgment of the Appellate Court and Singh’s convictions were affirmed.